The purpose of this Policy is to describe how Dacland complies with the privacy requirements in protecting the personal information Dacland holds about individuals. This Policy is applicable to Dacland and its controlled entities (collectively referred to as “Dacland” below).

Personal Information

Personal information is defined as information or an opinion that can identify or can reasonably identify an individual.

Collection of Personal Information

The type of personal information that Dacland collects will depend upon what dealings the relevant individual may have with Dacland. Dacland may collect and hold information about:

purchasers or potential purchasers (for example, when purchasing a Dacland product or service, or when responding to requests for information about a Dacland product or service);

suppliers (for example, when establishing records and systems to enable payment for goods);

job applicants (for the purposes of employment);

individuals as contractors (for example, when establishing records and systems to enable payment for services);

individual investors in our investment vehicles (for example, when establishing accounts and to carry out due diligence);

individuals as shareholders in Dacland;

other individuals who may come into contact with Dacland.

Dacland only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but are not limited to:

information about the individual that is required or authorised by law;

the individual’s tax file number;

the individual’s opinion about Dacland’s products, services or staff.

The Privacy Act imposes restrictions on collecting sensitive personal information (this includes information about religious views, ethnicity, political opinions, personal health information). Dacland generally does not collect sensitive personal information about an individual. However, in certain circumstances, Dacland may collect some sensitive information if it is necessary to allow Dacland to deal with the individual and the individual has provided consent for Dacland to do so. Whenever it is reasonable and practical to do so, Dacland only collects personal information directly from the individual. In some circumstances, personal information may be provided to Dacland by other parties such as the individual’s agent and/or professional advisor(s). Dacland will take reasonable steps to inform the individual that it has the individual’s personal information, unless it is obvious from the circumstances.

Use and Disclosure of Personal Information

Dacland operates a number of businesses which handle personal information. Dacland’s policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. Dacland may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.

If Dacland wishes to use or disclose the personal information in other circumstances, it needs to obtain the individual’s consent to do so.

In general, Dacland uses personal information for the following purposes:

providing products, services or investment opportunities that have been requested;

providing ongoing information about Dacland products, services or investment opportunities to individuals that Dacland believes may be interested;

complying with regulatory and legal obligations;

recruiting of employees and contractors.

Disclosing Information to Other Parties

Dacland may disclose personal information to other entities within Dacland.

External parties may be given access to personal information held by Dacland in certain circumstances.

These include, but are not limited to:

Dacland’s contractors and service providers who assist Dacland in the operation of its business or to provide a customer service (for example, professional advisors, or a company which helps maintain Dacland’s computer systems or sends out Dacland’s mail);

joint venture partners, including for the purposes of seeking relevant regulatory approvals;

third party lenders and insurers;

the Australian Securities and Investments Commission and to other government agencies as agreed to or required by law;

anyone authorised by a provider of personal information;

relevant parties in situations when Dacland is required by law to provide the information.

Dacland limits the information disclosed to external parties to what is required for them to perform their services for Dacland or the relevant individual, or what is required by law. Dacland requires these parties to agree to Dacland’s Privacy Policy and to strict conditions governing how this information may be used and stored.

Dacland may sometimes disclose personal information overseas to allow external parties to perform their services for Dacland but Dacland will only do so in accordance with the Australian Privacy Principles.

Dacland does not sell personal information to entities outside Dacland.

Marketing

Dacland may send marketing materials to its customers or investors or potential customers or investors where Dacland has collected the personal information from the individual and the marketing material is related to the purpose for which the information was collected.

The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has not been collected directly from the individual or where sensitive information is involved.

If the customer or investor no longer wishes Dacland to use his or her personal information in order for Dacland to provide marketing materials, the customer or investor is to advise Dacland via the relevant method provided for in the electronic marketing message sent to the customer or to the email address info@dacland.com.au. Dacland will act and amend its records promptly.

Cookies

A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) during a visit to a Dacland web site. Cookies are necessary to allow the Dacland web site and the user’s computer to interact effectively and enhance security. Cookies can record information about the user’s visit to assist Dacland in better understanding the needs of the user. If users of a Dacland website do not wish to receive any cookies, they should set their browser to refuse cookies but this means that they may not be able to use the Dacland website.

Applying for Employment with Dacland

Dacland collects personal information from individuals who submit applications or register interest for employment with Dacland. If the application is unsuccessful, Dacland may retain the information in case a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that he or she can contact Dacland to request Dacland not to retain the applicant’s information.

Security of Personal Information

Dacland will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. Personal information is held on secure servers or in storage located in controlled environments. Dacland employees are required to maintain the confidentiality of any personal information held.

If other parties provide support services, Dacland requires them to agree to appropriately protect the privacy of the information provided to them.

Notification of Collection of Personal Information

When Dacland collects personal information, Dacland provides notification of the collection to the individual to inform the individual about the purpose for the collection, the types of entities that the information is disclosed to, the overseas recipients the information is disclosed to (where applicable), and that Dacland Privacy Policy contains information about how the individual may access the personal information held by Dacland and how the individual may make a complaint.

Access to Personal Information

Any individual can request access to the personal information Dacland may hold about them. To obtain access to the information, the individual needs to write to Dacland at info@dacland.com.au. Dacland will require evidence to verify the identity of the individual.

This service is free of charge unless the personal information requested requires preparation time. In this situation, Dacland will provide an estimate of how much this service will cost and request agreement before proceeding.

In normal circumstances, Dacland will provide the individual with access to the individual’s personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, Dacland will provide the individual with the reason.

Changing Personal Information

If an individual wishes to update personal information that the individual believe may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to the Dacland at info@dacland.com.au requesting the information to be updated or deleted.

Changes in the Future

Dacland reserves the right to change this Privacy Policy at any time. Dacland will notify any changes by posting an updated version of the Policy on the Dacland website at http://dacland.com.au.

Complaints

An individual can make a complaint about the way in which Dacland has handled an individual’s personal information by writing toinfo@dacland.com.au. Dacland will endeavour to act promptly in response to a complaint.

Additional Information on Privacy

For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at http://www.oaic.gov.au.